DEPARTMENT OF HUMAN SERVICES

Self-Evaluation Plan

Title II of the Americans with Disabilities Act (ADA)Programs, Services and Activities

ISSUED AND APPROVEDby the Director

Department of Human Services

Patricia McManaman

Effective August 1, 2014Prepared by

Personnel OfficeCivil Rights Compliance Staff

P. 0. Box 339Honolulu, Hawaii 96809-0339

Telephone: (808) 586-4955E-mail: gwatts@dhs.hawaii.gov

STATE OF HAWAII

Web: http://humanservices.hawaii. gov

TABLE OF CONTENTS

Page

Executive Summary iiIntroduction - Purpose of Self-Evaluation 1Non-Discrimination Statement 1Designation of Americans with Disabilities Act (ADA) Coordinator 2Key Activities 2Programs and Services Description 3

Benefit, Employment and Support Services Division (BESSD) 4Med-QUEST Division (MQD) 4Social Services Division (SSD) 4Division of Vocational Rehabilitation (DVR) 4Hawaii Public Housing Authority (HPHA) 5Office of Youth Services (OYS) 5Commission on the Status of Women (CSW) 5Hawaii State Commission on Fatherhood 5Support Services 5

Officials Responsible for Programs and Services 6Self-Evaluation Process for Programs and Services 6Reasonable Program Modifications 8Surcharges and Additional Requirements 9Integrated Settings and Separate Programs 9Contracting with External Organizations 9Procurement Contracts 11Communication Access 11TDD Communications 12Website Accessibility 12Emergency Warning Systems 12Access Information 13Facilities Assessment 13

Summary of Inaccessible Features 13Program Access Options 14

Summary 14

Appendices 15

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Executive Summary

This Self-Evaluation Plan is a voluntary effort to comply with Title II of the Americans with DisabilitiesAct, As Amended (ADAAA) at the Hawaii Department of Human Services (DHS). Purposes of the planinclude, and are not limited to: 1) identifying services, policies, and processes that need attention;2) maintaining compliance with ADAAA relative to State-owned and leased facilities; 3) assuringcommunication access and emergency warning provisions for disabled individuals; and 4) updating anddisseminating ADA notices and policies regarding improving access to programs, services and activitiesas well a preventing discriminatory practices.

This two-year plan (August 1, 2014-July 31, 2016) is general in nature to allow for flexibility inprovision of services as well as to allow for changing needs and requirements. More specific details andobjectives are provided on an annual basis to DHS Divisions, Administratively Attached Agencies andCommissions. In summary, some preliminary self-evaluation activities continue as follows:

V Involve persons with disabilities in access discussions

V Update programs, services and activities for access, and compliance purposes

V Inform and train sub-recipients

V Distribute annual Director’s Internal Communication (ICF) on non-discriminationpolicies

V Refresh Task Force Representation regularly

V Remind supervisors and staff of their role in providing auxiliary aids and modificationson a timely basis

V Monitor capabilities of staff in using and offering assistive devices

V Monitor and inform about emergency evacuation procedures for persons with disabilitiesin State-owned and leased buildings

V Collect data as required to support integration of individuals with disabilities and/orlanguage barriers into programs, activities and services

V Develop and educate staff in policy and procedure changes

V Conduct site visits for facilities and language assessment purposes

V Submit Civil Rights Report to USDA, Office of Civil Rights, (OCR) as follow-up toSNAP management evaluation process, as required.

DEPARTMENT OF HUMAN SERVICES

PROGRAMS, SERVICES, AND ACTIVITIES

Self-Evaluation Plan

August 1, 2014—July 31, 2016

Introduction

Purpose of Self-Evaluation

State and local governments are required to conduct self-evaluations of services, policies andpractices, in accordance with Title II of the Americans with Disabilities Act, As Amended(ADAAA), 42 U.S.C., Section 12101. The purpose of self-evaluation is to identify services,policies and practices that might not comply with Title II requirements, and to correct anydiscrepancies to bring an entity into compliance.

A Civil Rights Compliance Review conducted by the Office of Civil Rights Food and NutritionService (FNS) of the U. S. Department of Agriculture (USDA) in 2010 focused on six key areas.A management evaluation by USDA was completed in February and March of 2014 as well. Asa part of the SNAP Management Evaluation Plan, the Department of Human Services, (DHS)Civil Rights Compliance Staff, provides a progress report to USDA, Office of Civil Rights asrequested. The focus of that report includes the following six areas:

1. Annual Civil Rights Training2. Unannounced Site Visits3. Policies and Services for Limited English Proficient (LEP) Clients4. Building and Program Accessibility for Persons with Disabilities5. Public Notifications and Procedures related to Filing Discrimination Complaints and

Processes for Tracking Service Delivery Complaints6. Collection of Data on the Limited English Proficient Populations in the Hawaii

service areas

Non-Discrimination Statement

It is the policy of the State of Hawaii that no qualified individual with a disability is excludedfrom participation in, denied the benefit of, or is otherwise subjected to discrimination by anyprogram, service or activity of the State on the basis of disability. This is also supported by theDepartment of Human Services (DHS) Policy and Procedures 4.10.3 (Appendix A) and 4.10.4(Appendix B).

Joint non-discrimination statements appear on DHS websites and are available in ten languages.Additionally, USDA’s nOn-discrimination statement appears on the DHS website in the CivilRights Corner httn://hurnanservices.hawaii.gov in three languages. Public notices are posted inwaiting rooms, such as the USDA’s, 475B notice.

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In keeping with the above policies and statements, DHS is committed to providing an equalopportunity for all persons to participate in its services, programs and activities. Thiscommitment is reflected in Director’s Memorandum 14-01, dated January 6, 2014 (Appendix C),an internal communication informing staff of the department’s responsibilities.

The Department’s non-discrimination statement, all related directives, memoranda, and publicnotices, apply to all Divisions, as well as its two administratively attached agencies and twocommissions. The Hawaii Public Housing Authority (HPHA), an administratively attachedagency which has considerable autonomy, has taken additional measures to ensure that the publicis informed of its commitment to non-discrimination specifically in public housing under the FairHousing Act.

Although the DHS provides an equal opportunity to participate in its services, programs andactivities, persons who believe they have been discriminated against may file a discriminationcomplaint in accordance with the Departmental Discrimination Complaint Policy andProcedures (4.10.1) (Appendix D).

Designation of ADA Coordinator

The DHS Civil Rights Compliance Staff is the designated ADA Coordinator for the department.Questions, complaints and/or concerns may be routed to:

DHS — Personnel Office E-mail: gwatts@dhs.hawaii.govCivil Rights Compliance Staff Fax: (808) 586-4990P. 0. Box 339 Phone: (808) 586-4955Honolulu, Hawaii 96809-0339

Additionally, Hawaii Public Housing Authority ADA Coordinator, Kiriko Oishi, can becontacted at: Kiriko.U . Oishi(hawaii.gov

The Hawaii Public Housing Authority Phone: (808) 832-46801002 North School Street, Building J Fax: (808) 832-3866Honolulu, Hawaii 96817 TDD: (808) 832-3817

Self-Evaluation Process within the Department

Key Activities

An ACCESS Task Force, composed of representatives from the various programs and staffoffices, was organized to assist the ADA Coordinator in the self-evaluation process and othercompliance activities. The vision, mission and standards of services are provided in Appendix I.Task Force representation is refreshed annually. The following areas are represented on theACCESS Task Force:

Administrative Appeals Office (AAO)Benefit, Employment and Support Services Division (BESSD)Civil Rights Compliance Staff (CRCS)Division of Vocational Rehabilitation (DVR)

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Hawaii Public Housing Authority (HPHA)*Limited English Proficiency Project Manager (DIR)Med-QUEST Division (MQD)Office of Youth Services (OYS)Social Services Division (SSD)

Jn addition to being part of the DHS’ ACCESS Task Force, the HPHA Representativecoordinates the internal self-evaluation process, which includes obtaining feedback fromstaff involved in providing programs, services and activities to the public and who areresponsible for HPHA facilities under the Fair Housing and Rehabilitation Acts.

The key activities of the DHS ACCESS Task Force relative to the self-evaluation processinclude, but are not limited to:

Meeting semi-annually to consider changes/improvementsProcedures and practices reviewDissemination of ADA Notice and Self-Evaluation PlanPlan of action for practices relative to accessProviding suggestions for addressing areas of non-complianceCollecting and analyzing relevant population data

Involvement of People with Disabilities

Persons with disabilities are involved in the self-evaluation process at various levels. Within theDepartment, employees with disabilities are invited to participate in compliance activities. Toobtain input from external organizations, this Self-Evaluation Plan will be made available to thefollowing organizations that are responsible in some way for providing services to persons withdisabilities.

• Disability and Communication Access Board, Hawaii Department of Health• Ho’opono Services for the Blind Branch, DVR, DHS• Aloha State Association of the Deaf, Honolulu, Hawaii• U. S. Department of Agriculture, Office of Civil Rights, Region IX

Frequent attempts are made to involve persons with disabilities to access discussion.

Programs and Services

The. DHS offers a wide range of state and federally funded programs and services to the publicthrough four divisions, two administratively attached agencies, and two commissions. Suchprograms and services include, but are not’ limited to, welfare assistance (financial and SNAPbenefits), employment and training, child care, medical assistance, child welfare services, adultprotective and community services, vocational rehabilitation, public housing, and youth services.A state-wide Commission on the Status of Women (CSW) and the Hawaii State Commission onFatherhood are also under the DHS.

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Description of Programs and Services

Benefit, Employment and Support Services Division (BESSD)

The mission of BESSD is to help economically disadvantaged persons attainself-sufficiency. In an effort to achieve this, BESSD administers Financial Assistance,Supplemental Nutrition Assistance Program, and Employment and Training Services.The Division also provides Child Care Connection Reimbursement services for familiesin which the parent(s) is/are employed or in training. The Homeless Program, transferredto BESSD from HPHA in 2010, solves problems and provides assistance to homelessindividuals in Hawaii.

2 Med-QUEST Division (MQD)

The mission of Med-QUEST (MQD) is to provide the overall management of the plans,policies, regulations and procedures of the Division’s medical assistance programs,public information, staff and clerical assistance and support services; to develop andmaintain working relationships with health plans, providers, Federal and State authorities,community agencies, client advocacy groups and others. This Division is alsoresponsible for providing home and community-based support services to disabledchildren and adults.

3. Social Services Division (SSD)

SSD administers the Child Welfare Services Branch, commonly known as ChildProtective Services (CPS) and the Adult Protective and Community Services Branch(APCSB), commonly known as Adult Protective Services (APS). Working with theOffice of Information Technology, the APCSB is listing its APS e-mails on its APSReporter Form to promote reporting from the public who are hearing impaired and asanother means to report abuses against the disabled and/or elderly.

4. Division of Vocational Rehabilitation (DVR)

DVR is divided into the following programs:

a. Vocational Rehabilitation — provides services to eligible individuals withdisabilities to become productive members of Hawaii’s workforce.

b. Ho’opono, Services for the Blind - provides services to eligible blind, deaf/blindand visually-impaired individuals which include vocational rehabilitation,adjustment classes, public education and blindness prevention activities.Ho’opono also maintains a statewide blind registry.

c. Disability Determination - determines disability for Social Security DisabilityInsurance and Supplemental Security Income benefits.

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5. Hawaii Public Housing Authority (HPHA), administratively attached to DHS

The HPHA administers federal and state public housing and rental subsidy programs andother miscellaneous rental programs. The primary service of these programs is providingsafe, decent and affordable housing to low income families.

6. Office of Youth Services (OYS), administratively attached to DHS

The OYS was established by legislature in 1989 and administratively placed within DHS.The OYS provides and coordinates a continuum of services and programs for youth-at-risk to prevent delinquency and reduce the incidence of recidivism. The OYS also strivesto provide a clear sense of responsibility and accountability for all youth services inHawaii. Although a core responsibility of the OYS is to manage and operate the HawaiiYouth Correctional Facility (HYCF), the agency places great emphasis on providing andsupporting “front end” prevention, diversions, and intervention services.

The OYS focuses on programs that address youths’ needs from prevention toincarceration and aftercare. The OYS administers the following programs and servicethrough Purchase of Service (POS) providers who are contracted by the OYS: PositiveYouth Development, Non-School Hours Programs, Youth Gang Prevention andIntervention, Truancy Prevention, Outreach and Advocacy, EducationNocation Services,Homeless Youth Services and Community-Based Residential Services.

The HYCF insures public safety by providing programs and services that work towardsuccessful reintegration of incarcerated youths within a safe, secure and just environment,which promotes adolescent development.

7. Commission on the Status of Women (CWS)

This administratively attached commission is a two-person office providing servicesspecific to the needs and status of women.

8. Hawaii State Commission on Fatherhood

The mission of the Hawaii State Commission on Fatherhood is to promote healthy familyrelationships between parents and children by emphasizing the important role fathers playin the lives of their children. The Commission serves in an advisory capacity to stateagencies and makes recommendations on programs, services, contracts, policies, andlaws relating to children and families.

Support Services

Six staff offices provide support services to the aforementioned divisions, administrativelyattached agencies and commissions: 1) Administrative Appeals Office, 2) Fiscal ManagementOffice, 3) Office of Information Technology, 4) Budget, Planning and Management Office,5) Audit, Quality Control and Research Office, 6) Personnel Office. Of these, the AdministrativeAppeals Office (which conducts administrative hearings for clients), and the Personnel Office(which provides employment services), maintains public contact on a regular basis.

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Programs, services and activities are updated as needed for access and compliance purposes.

Officials Responsible for Programs and Services

The following is a list of officials responsible for the planning, preparation, coordinationand delivery of programs, services, and activities under their supervision:

DHS Director Deputy Director

Patricia McManaman Barbara A. Yamashita

Division AdministratorsBESSD DVR

Pankaj Bhanot Albert Perez

MQD SSDDr. Kenneth Fink Mona Maehara

Agency Executive DirectorsHPHA OYS

Hakim Ouansafi David Hipp

COmmjSsjLIC1JtjVe DirectorsCSW FATHERHOOD

Catherine Betts Barbara A. Yamashita, Acting

Self-Evaluation Process for Programs and Services

Equal Opportunity to Participate and Benefit

The ADAAA states that a public entity: 1) may not deny a qualified individual with a disabilityan opportunity to participate and benefit from any program; 2) may not afford an opportunitythat is not equal to or not as effective as that provided others; and 3) may not impose eligibilitycriteria for participation in programs that screen out people with disabilities either directly orindirectly, unless such criteria are necessary for the provision of the program’s activities orservices.

As indicated previously in the Description of Programs and Services, DHS provides a wide rangeof programs, services, and activities to the public and is a public entity. Although said programs,services and activities are designed and administered to serve all individuals equally, there maybe circumstances in which participation of a person with a disability may be excluded orrestricted. However, DHS believes that these exclusions and/or restrictions are necessary eitherto the operations of a program, or to ensure the safety of program participants, and does notdiscriminate against persons with disabilities. The following identifies examples of DHSprograms that may result in necessary exclusions or restrictions:

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The Child Care Connection, Hawaii’s licensing requirements for child care providers contractingwith the DHS, may restrict or exclude the participation of certain individuals with disabilities.The provision child care, usually for children not yet school age, requires the provider to be ableto meet all the health and safety needs of the children in their care. For example, a provider mustbe able to carry infants/toddlers and escort older children out of a home and/or facility withoutassistance.

If persons with disabilities can demonstrate that they are able to meet all health and safetyrequirements, as well as other eligibility criteria, they will not be denied an opportunity tobecome licensed.

The MQD currently administers two major medical assistance programs: The Hawaii QUESTProgram and the QUEST Expanded Access (QExA) program. The DHS is moving to QUESTIntegrated, which will collapse these two programs to one. Currently, the QExA program isdesigned to better integrate and deliver health care to individuals who are sixty-five years orolder, blind, or certified as disabled by the Social Security Administration or by the State, whomay have more complex needs or community-based services requiring a greater degree ofcoordination. Accordingly these individuals are directed to the QEXA program and are ineligibleto participate in the Hawaii QUEST program. For an update on the MQD KOLEA Project,please see Appendix K.

The SSD is sometimes presented with circumstances when participation of persons withdisabilities may be excluded or restricted. For child welfare services, the choice of foster homesfor children with disabilities may be restricted to those homes where the family is properlytrained to care for these children. Additionally, foster home certification criteria may excludecertain prospective foster parents with disabilities, if they are unable to demonstrate how theywould care for the needs of children. In both instances, the exclusions or restrictions arenecessary for the health and safety of all involved parties.

A person with a disability may be excluded from participating in an adult day care program, ifthe nature of the disability is such that the person would be better served through anotherprogram. A skilled nursing or intermediate care facility, rather than an adult day care, forexample, may be a better choice for a severely disabled individual. Again, this exclusion isnecessary to the health and safety of the participants.

The DVR is unique in that all of it programs and services are designed to assist persons withdisabilities. However, because participation is contingent upon the nature of a person’sdisability, there may be circumstances where an individual may be excluded or restricted fromparticipation in any given program. For example, eligibility requirements set forth by theRehabilitation Act and the Social Security Act may exclude ineligible persons from participationin the Vocational Rehabilitation employment and training services. The exclusion of suchindividuals is necessary to comply with federal requirements. To disregard these requirementsmay fundamentally alter the nature of the programs and result in fiscal sanctions or loss offederal funding.

In its public housing programs, HPHA provides accessible housing units to eligible tenants withdisabilities (i.e., mobility impaired, and hearing and visually impaired). Hawaii AdministrativeRules, Section 17-2028-40, “Occupancy of Accessible Units” outlines procedures for filling saidunits.

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Services provided by the HYCF could identify circumstances when youth with disabilities maybe restricted from participation in a “work line.” For example, a youth who has a mobilityimpairment may be restricted or excluded from working on the HYCF’ s ranch. However, theyouth may be assigned to other work activities, such as performing work in an office setting.The exclusion or restriction is necessary for health and safety reasons.

Reasonable Program Modifications

Public entities are required to make reasonable modifications to policies or practices in order toavoid discrimination towards people with disabilities. A modification is not required, however,if it would fundamentally alter the nature of the program or activity.

The DHS recognizes that training is necessary for staff (who have direct contact with the public)to be properly trained in accepting and processing requests for reasonable accommodations andmodifications. The Department informs and trains sub-recipients upon request.

Although most programs have informal processes for modifying their practices, a formalprocedure consistently applied throughout the Department is designed to address the needs ofpersons with disabilities. This assures that all staff are aware of the Department’s obligation toprovide modifications and how to respond to requests. However, responding to requests formodifications may differ by division on a case-by-case basis.

The DVR has an established practice for providing program modifications to clients withdisabilities. Essentially the DVR notifies the public of the availability of program modificationsupon request through public meeting notices, appointment letters, and telephone contacts, and isotherwise open to provide modifications that would effectively meet the needs of an individual,taking into consideration his/her preference. For example, when a cognitively impaired client orapplicant is unable to complete necessary paperwork, arrangements are made by DVR staff toensure that proper assistance is provided.

The Eligibility Workers of the income maintenance and medical assistance programsadministered by the BESSD and MQD, respectively, are advised and are aware that officeeligibility interviews, which are normally required, may be waived for persons with disabilities.If participants are unable to come to the office, alternative methods of interviewing are practiced.For instance, telephone interviews, home visits, or interviews with an authorized representativeare regularly conducted to ensure that persons with disabilities are provided an equal opportunityto participate in programs and services.

In public housing, the JEIPHA makes reasonable accommodations to enable persons withdisabilities to have an equal housing opportunity. Similar to the BESSD and MQD, eligibilityreviews that are normally conducted in person at various HPHA offices or housing units can beconducted by telephone, with an authorized representative, or at an off-site location that isconvenient to both parties, including at the client’s residence. In addition, modifications to abuilding or unit may be provided to allow better access to the facilities, such as adding a ramp orwidening a doorway.

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Understanding that very few youth with disabilities are committed to the HYCF, the OYSmodifies work and recreational programs, when necessary to allow participation of such youth.For example, if youth with a mobility impairment were unable to participate in a recreationalactivity, the OYS would engage in finding alternative activities for that youth. Similarly, forwork programs, modifications are made to allow participation by a youth with a disability in themost integrated setting possible.

A departmental “Equal Opportunity to Services” Notice informs participants that the DHS canmake modifications to their program to accommodate individuals. It informs clientele that theDHS will provide sign or other language interpreters and information in alternate formats. TheDHS distributes annually Director’s Internal Communication Form (ICF) on non-discriminationpolicies.

Surcharges and Additional Requirements

Public entities may not impose extra charges upon people with disabilities to cover the costs ofeffective communication, program modifications, or access features, and may not impose anyadditional requirements or burdens on people with disabilities that they do not require of all otherparticipants in the program.

For all DHS programs, services and activities, there are no circumstances in which persons withdisabilities would be asked to pay a fee or meet any other requirements not imposed on otherprogram participants.

Integrated Settings and Separate Programs

Separate programs or activities are permitted only when necessary to ensure equal opportunity.When separate programs are provided, qualified people with disabilities cannot be excluded fromparticipating in regular programs.

It is departmental policy that participants of DHS programs, services and activities shall not bedenied the opportunity to participate in a regular (integrated) program even though anotherseparate program may exist and may be more appropriate.

As mentioned previously, all DVR participants are people with disabilities. Separate programs,services and activities exist to fulfill the varied needs of such individuals. For example, certaindisabilities may require special services, such as sign language interpreters, readers, Braillematerials, etc., to ensure equal access to programs and services. In addition, the Randolph-Sheppard Act gives priority to persons who are blind to operate vending facilities on Federalproperty. Similarly, the Hawaii Revised Statutes, Section 102-14, authorizes persons who areblind and visually impaired to operate vending facilities and machines in State or County publicbuildings.

While most youth attend school and participate in classroom activities, the HYCF occasionallywill request tutoring for youth in their living quarters when it is determined that their disruptivebehavior is detrimental to the rest of students in the classroom. Olomana School at HYCFprovides tutoring for those students on restriction due to disruptive classroom andlor modulebehavior. Once students are able to maintain safe and appropriate behavior they are reintegratedback into the regular educational setting.

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Contracting with External Organizations

When a public entity contracts with other organizations to provide programs and services to theentity’s constituents, the public entity retains responsibility for ensuring that the contractorprovides the services and activities in a non-discriminatory manner consistent with therequirements of Title II and other Federal regulations. The DHS regularly monitorssub-contractors.

An extensive number of contractors currently provide services on behalf of DHS and its attachedagencies and therefore, we have elected not to list them in this document. However, for specificinformation regarding contracts within the various programs, inquiries may be made with theDHS Civil Rights Compliance Office at the address and phone number listed above. All DHSnon-bid contracts shall contain the following language:

“No person performing work under this Agreement, subcontractor, employee, or agent ofthe CONTRACTOR, shall engage in any discrimination that is prohibited by anyapplicable federal, state or county law.”

Furthermore, standard language requiring contractors to comply with the law, shall read asfollows:

“The CONTRACTOR shall comply with all federal, state, and county laws, ordinances,codes, rules and regulations, as the same may be amended from time to time, that in anyway affect the Contractor’s performance of this Agreement.”

The OYS provides services exclusively though Purchase of Service (POS) contracts. Included intheir contracts is a section entitled “General Conditions for Health and Human ServicesContracts” (AG Form 1 03F, General Conditions) which includes the following language:

1.3 Compliance with Laws

1.3.3 Persons with Disabilities. The PROVIDER shall implement and maintain allpractices policies and procedures required by Federal, State, or County law,including, but not limited to the Americans with Disabilities Act (942 U.S.C.12101, et seq.) and the Rehabilitation Act (29 U.S.C. 701, et seq.)

1.3.4 Nondiscrimination. No person performing work under this Contract, includingany subcontractor, employee, or agent of the PROVIDER, shall engage in anydiscrimination that is prohibited by an applicable Federal, State, or County law.

The HPHA contracts with private property management companies to operate many State andFederal public housing projects. To ensure that contractors are aware of their obligation underthe law, HPHA provides training on Section 504 of the Rehabilitation Act.

BESSD’s Homeless Branch staff received ADA (Title II and III) training from the StateCommission on Persons with Disabilities to enable them to monitor their contracted serviceproviders.

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Although contractors are informed of their obligation to comply with all Federal, State andCounty laws, the DHS believes that compliance with the ADA should be discussed directly withthe contracting agent/s to ensure understanding of their obligations. Furthermore, DHS shallensure staff that monitor the contracts for compliance have full knowledge of ADArequirements.

The Fiscal Management Office shall periodically review DHS contracts to incorporate morespecific language relative to compliance with the ADA and other civil rights laws, rules andregulations, including, but not limited to, inclusion of specific assurances appropriate to therespective funding entities.

Procurement Contracts

In selecting procurement contractors, a public entity may not discriminate on the basis ofdisability. There should be no circumstances in which consideration related to disability wouldinfluence the choice of a procurement contractor. Program Contract Monitors must assure thatthis does not happen.

Communication Access

The State of Hawaii shall ensure that all individuals with disabilities have communication accessto programs, services and activities of the State, which are equally effective as that provided toindividuals without disabilities. Departments and agencies of the State of Hawaii shall providespecific communication access in the form of auxiliary aids or services upon the request of aqualified individual with a disability. It is also State policy that a request must be received fiveto seven days prior to the date of an event that an auxiliary aid or service is needed. (Please seeAppendix J for updated Request for Auxiliary Aid Form.)

Auxiliary Aids and Services

In keeping with the aforementioned policy, the DHS provides the following auxiliary aids andservices upon request by a qualified individual with a disability:

Visual Hearing and Speech CognitiveLarge Print Sign Language Interpreters SignageReaders TDD Simplified DirectionsBraille Telephone Relay ServiceAudiocassette Paper and PenMagnifier

V

Computer Diskette

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The following auxiliary aids and services are made available upon request.

Hearing and Speech CognitiveAssistive Listening Devices Visual DisplaysAM or FM System (ATRC) ATRC Hawaiihttp://atrc.org/home/indexLbtrn 200 North Vineyard Boulevard, Suite 430E-mail: atrc-info@atrc.org Honolulu, HI 96817

Phone: 1-800-645-3007

The DHS monitors capabilities of staff in using and offering assistive devices.

Several divisions have an informal procedure for responding to requests for auxiliary aids andservices, which includes the consideration of an individual’s preference, and assesses theavailability of other equally effective means of communication. DHS’ Policy 4.10.3 and 4 apply.

TDD Communications

In addition to relay services, TDD communication devices are available at:

Oahu Hawaii6 DVR locations 2 DVR locations

6 BESSD locations 2 BESSD locations2 MQD locations 2 MQD locations1 HPHA location1 HYCF location3 PERS locations

Maui Kauai2 BESSD locations 1 DVR location

1 MQD location 1 MQD location1 BESSD location

The SSD explored the feasibility of installing TDDs for its CPS and APS Hotlines. However,because these Hotlines are equipped with answering machines which do not accept TDD calls, itwas determined that TDD hook-up was not feasible. Staff have been instructed thatTelecommunications Relay Service (TRS) shall be utilized as an alternate effective means ofcommunication. Moreover, if there is a high volume of calls that the SSD receives through theTRS, the Division shall reassess the need for TDDs.

The DVR has a Statewide Coordinator for the Deaf with a designated Video Phone (VP) line toaccommodate the deaf population. The DVR administrative office has a program specialistassigned to the VP and is fluent in American Sign Language as well as knowledgeable in deafculture, which is required for this position.

Video phones and relay service are most commonly used today by the deaf community and havereplaced TDD.

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Website Accessibility

Efforts have begun to enhance website accessibility for readers. A primer on websiteaccessibility, cosponsored by the Disability and Communication Access Board and the AssistiveTechnology Resource Center, offered information about the need for accessibility, standardsrelated to accessibility, practical approaches to accessibility and specific tools and techniques.

The Department’s public information officer also serves as the communications representative.

Emergency Warning Systems

The Office of the Director and Support Services Offices located in a state office building onOahu have emergency evacuation procedures that address the needs of persons with disabilitiesas do branch offices in DHS leased or state-owned buildings. The Fiscal Management Office isresponsible for planning/coordinating with the Department of Education overall evacuationprocedures during emergencies such as fire, for staff in the Liliuokalani Building.

The DVR, MQD, BESSD, SSD, OYS, and HYCF indicate that they have emergency evacuationprocedures, which include safe egress for persons with disabilities. Said programs indicate theplans include a means to alert hard-of-hearing and deaf individuals of an activated alarm. Whilethe HYCF has a strobe alarm in its secured facility, the other divisions maintain that they haveimplemented a “buddy system” to assist hearing-impaired or deaf individuals.

In meeting with BESSD’s Oahu Branch, Neighbor Island Branch and Section Administrators, theAdministrators report with confidence that their offices and units have developed writtenemergency evacuation procedures for egress of disabled staff, clients, visitors and for staff toalert hearing-impaired and deaf individuals of an activated alarm and other needed assistance.The plans are now routinely posted in the offices. The Administrators will take necessary stepsto ensure that the evacuation plan is posted at all exits.

Most HPHA administrative offices have emergency evacuation plans and procedures but not alloffices specifically address the needs of persons with disabilities. In its public housing projects,some dwelling units are equipped with smoke detectors with strobe lights for the hearing-impaired. In addition, at some of its high-rises for the elderly, a list of frail and disabled tenants(those with known ambulatory, hearing and vision impairments) is compiled and provided to theHonolulu Fire Department.

Assistance will be provided by appropriate personnel to ensure that all DHS program officeshave emergency evacuation procedures, which include plans to ensure for the safety of personswith disabilities. The DHS will monitor and inform about emergency evacuation procedures forpersons with disabilities in State-owned and leased buildings.

Access Information

Access information is primarily provided over the telephone. Information about access is alsocommunicated by ADA Notice posted in all DHS units in public areas (Appendix E), publichearing notices, Internal Communication Form (ICF) and policy and procedure dissemination,and websites.

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The self-evaluation process will determine whether all staff are knowledgeable about providingaccess information. As such, training sessions regarding this matter, shall be provided in order toassure equal opportunity to services by persons with disabilities. Training can be face-to-face,video conferencing and/or computer based (CBT) via http://humanservices.hawaii.gov in theCivil Rights Corner. In 2014, the CRCS provided CBT training to all DHS staff and face-to-facetraining to registered clerical staff in the Administrative Procedures sessions. A copy of thattraining is also available on line (Appendix F).

Facilities Assessment

Summary of Inaccessible Features

The HPHA conducted a survey and hired a consultant to update the needs of its facilities toidentify structural barriers that may impede physical access. In addition, for HPHA-ownedFederal facilities, inaccessible elements were addressed through its Capital Fund Program.

As part of the self-evaluation process, an assessment of DHS offices located in both state-ownedand leased facilities will be conducted annually to determine the level of physical access topersons with disabilities.

Inaccessible elements of state buildings will be addressed administratively and/or throughDAGS. For offices in leased facilities, inaccessible elements may either be addressed by theprogram, through reasonable modifications to policies and practices, and other program accessoptions, or by removing structural barriers which impede access. Where offices have agreed tomodify their policies and practices to accommodate persons with disabilities, no renovations orimprovements will be recommended. All renovations and improvements must comply with 2010ADA Standards. All lease renewals must be reviewed by the DHS ADA Coordinator to confirmcompliance with 2010 ADA Standards.

Unannounced site visits to assist in identifying needs are conducted annually, have beencompleted for 2014 (Appendix G), and will be ongoing through 2016.

Program Access Options

Program access options for DHS facilities are listed in Appendix H.

Additionally, the HPHA set out to make reasonable modifications to its policies and practicesand take whatever steps necessary to ensure that identified barriers were addressedprogrammatically. Program access options for HPHA included, but were not limited to:1) performing outreach services; 2) contacting clients by telephone; 3) meeting with participantsat an alternate accessible site; 4) allowing an authorized representative to serve on behalf of aclient; 5) providing materials in alternate format; and 6) providing auxiliary aids and services.The Divisions are addressing and/or will be addressing program options for areas identified asneeding attention in unannounced site visits in 2014.

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Summary

In summary, this two-year plan, highlights DHS’ purpose for self-evaluation as required bySection 12101 of the Americans with Disabilities Act, designates an ADA Coordinator, sites keyactivities and names officials responsible. Programs and processes for self-evaluation aredescribed, communication access and web accessibility are highlighted as is information aboutemergency warning systems and facilities assessment through unannounced site visits.

Program access options, a list of 2014 site visits, ADA notice, related internal communication,and ADAAA related training are included in appendices.

Some preliminary self-evaluation activities continue as follows:

V Involve persons with disabilities in program and facilities access discussions

V Update programs, services and activities as required

V Inform and train sub-recipients in providing access and compliance

V Distribute annual Director’s ICF on non-discrimination policies

V Refresh Task Force Representation regularly

V Remind supervisors and staff of their role in providing reasonable accommodationsand modifications on a timely basis

V Monitor capabilities of staff in using and offering assistive devices

V Monitor and inform about emergency evacuation procedures for persons withdisabilities in State-owned and leased buildings

V Collect data as required to support integration of individuals with disabilities and/orlanguage barriers into programs, activities and services

V Develop and educate staff in policy and procedure changes

V Conduct site visits for facilities and language assessment purposes

V Submit Civil Rights Report to USDA Office of Civil Rights (OCR) as follow-up toSNAP management evaluation process as required

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APPENDICES

A DHS Policy and Procedures 4.10.3 dated July 9, 2009

B DHS Policy and Procedures 4.10.4 dated February 17, 2009

C Director’s ICF 14-01 dated January 6, 2014

D Departmental Discrimination Complaint Policy and Procedures, 4.10.1dated July 18, 2011

E ADA Notice

F Civil Rights Awareness Training

G List of 2014 Unannounced Site Visits with ICF dated February 3, 2014

H Program access options for DHS facilities

I Vision, Mission and Standards of Service

3 Request for Auxiliary Aid Form

K MQD KOLEA Project Update

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